General Comments
This is a disappointing and ultimately frustrating draft. It seeks only to set standards over existing practice, rather than demand action which would develop the aquaculture industrial towards environmental sustainability. It would pass as the industry’s internal standards document, merely proposing monitoring protocols for analyzing sediment and water quality, and for half heartedly addressing parasite and disease transfer and location issues. However, there is a feeling of déjà vu to the content, and the fact that we have moved little further forward over the past two decades. It threatens to standardise flawed operating procedures, rather than tackling the deep rooted problems associated with salmon aquaculture.

This response is made on behalf of the Salmon & Trout Association, Association of Salmon Fishery Boards and the Rivers and Fisheries Trusts of Scotland, and so is inevitably focussed on Scottish salmon farming, although the issues are mostly generic. Our comments are made with the knowledge that the Scottish industry intends to significantly increase production to fill the void left by deteriorating operating conditions in other countries – without first addressing its existing impact.

Specific Issues
Official denial – there is little in these draft standards that alludes to the severe impact salmon aquaculture has inflicted on wild salmon and sea trout and the surrounding freshwater and marine aquatic environment. Governments and industry are still in public denial, despite the wealth of peer reviewed scientific literature confirming the devastating effects of parasites and disease transferring from farms to wild salmon and sea trout; biological and chemical pollution emanating from farm units; and fish farm escapees adversely interacting with wild salmonids.

There are serious paradoxes in both Government, agency and industry positions on this with respect to the inspiration of and participation in initiatives that are overtly established to relieve these problems and the public positions and statements of these organisations on this matter (NASCO / TWG / Strategic Framework for Scottish Aquaculture / SNH policy statements etc). We believe that for an environmental NGO of WWF’s stature and reputation to engage in discussions about mitigation of impacts of this nature without a clear recognition and articulation of these problems is untenable.

7 Point Plan – is vague and fails to show any teeth. Its underlying principle seems to be the need to prove parasite and disease impact on wild salmonids against ambient natural levels before any action is required. This is further proof of official denial, and completely ignores the precautionary principle. The plan also suggests that impacts can be ‘minimised, but this is an illusionary target impossible to achieve under current open system management. Wild fish, especially juveniles, can only be protected if there is no interaction with farmed fish.

Safe distance location - the draft discusses what might be a safe distance for salmon farms to be located away from wild salmonid migration routes. It is impossible to make a generic prediction of a safe distance, given the site specific nature of these impacts. The location of salmon farms must be established on an individual site basis, taking into account specific local issues and reliable lice dispersal models – not stabs in the dark.

Non natives - The draft suggests that non native species can be introduced if they are assessed to pose an acceptable level of risk. This is totally irresponsible and unacceptable to wild fish interests – non native control is impossible under an open system management.

Freshwater smolt units – there is little mention in the draft standards covering smolt producing units in freshwater where the risk of introgression due to serial escapes is higher than from marine cage sites given the life stage at which escapes will occur. This is an extremely serious omission, particularly as Norway, the world’s largest producer of farmed salmon, already prohibits smolt units on rivers containing wild salmonids. This should be the basic standard and targeted aspiration across all Atlantic salmon producing countries where there is conflict with wild stocks

Action
To remain credible in this debate, WWF must make clear recommendations to move the industry towards environmental sustainability. Without this, the document is worthless.

• It must be made clear that the Precautionary Principle is the overriding concern of these standards.

• WWF must also commit to the principle that economic issues can never be allowed to override environmental protection.

• Relocation – It is clear that, under current available technology, there is an inherent incompatibility at many sites between intensive farmed cage units and sustainable wild migratory salmonid fisheries. This problem will only be relieved through the strategic relocation from sensitive sites. If WWF is looking for common ground with the industry, then there could be no better and more credible short to medium term strategy than the pursuit of the objective of actively encouraging the development of large offshore sites where impacts are likely to be manageable, to allow the relief of pressures on sensitive inshore sites. This may allow the industry to expand but, whilst doing so, could create opportunities for the relief of pressures in certain locations and in so removing these farms allow for targeted monitoring and research to start to quantify the nature of these impacts.

• Triploids – in the medium term, the safest way to protect wild salmon gene pools is to make the stocking of triploid salmon mandatory – within agreed time scales - on all salmon farms. WWF should include this issue as an industry target.

• Enclosed systems – the only long term solution to making aquaculture secure and environmentally sustainable is to move to totally enclosed systems, whether on land or at sea. Such installations would genuinely minimise escapes (rather than providing lip service to the issue), prevent transfers of parasites and disease, and allow waste effluents and chemical treatments to be collected and treated in order to avoid environmental pollution. The industry must research the necessary technology as a matter of urgency, and within time scales set by the Scottish Government after consultation with aquaculture and wild fish interests.

Summary
As an environmental NGO, WWF MUST be prepared to target, articulate and address some of the obvious problems associated with negative interactions between wild and farmed fisheries, whether in the Atlantic or Pacific. Without that overt commitment, this document will fail totally to attract support from the main wild fisheries bodies. WWF should clearly identify solutions such as the relocation of sites away from sensitive areas, but even these must be seen purely as short to medium term remedies. The overwhelming view of the reactions to this paper, and similar initiatives in other countries, is that both marine and freshwater salmon aquaculture must be separated from wild migratory fish. With evidence of unnaturally high lice drift over more than 70 miles in some locations, this is the only way to stop parasite and disease transfer, and guard in any credible way against fish farm escapes interacting with wild fish.